The regulation of genetically engineered salmon under the Canadian Environmental Protection Act, 1999

Petition: 439

Issue(s): Biological Diversity; Compliance and Enforcement; Fisheries; Science and Technology

Petitioner(s): A Canadian Organization

Petitioner Location(s): Halifax, Nova Scotia

Date Received: 6 February, 2020

Status: Completed—Response(s) to petition received

Summary: The petition is concerned with the potential environmental and health risks related to the production of transgenic (genetically engineered) salmon eggs in Rollo Bay, Prince Edward Island by AquaBounty Technologies Inc. It questions whether adequate containment measures have been taken for the land-based enclosed fish tank production facility the company uses. The petition raises concerns about risks from transgenic and non-transgenic fish being produced within the same facility. It cites the risk and environmental consequences should human error result in mixing of these two different types of fish.

The petition references a 2019 Joint Assessment Report on environmental risks completed by the federal government in response to a 2018 notification regarding AquaBounty’s proposal to manufacture transgenic salmon eggs alongside non-transgenic eggs. The petition notes that a 2013 Significant New Activity Notice (SNAC) for AquaBounty’s was limited to transgenic salmon eggs. It questions why the 2018 notification which now includes manufacture of non-transgenic eggs alongside transgenic eggs did not trigger the requirement for a new SNAC, due to potential risk and exposure from mixing the two types of fish. The petition asks when a new SNAC will be issued, arguing that producing both types of fish constitutes a “new activity” that requires additional information from the proponent on test results of potential “pathogenicity, toxicity or invasiveness.” It seeks to know whether in the absence of a new notice, the company would be able to change its containment procedures without submitting a new notification.

The petition states that the production and risks of exposure had not being assessed under the Canadian Environmental Protection Act, 1999 (CEPA 1999) because the company had been granted a waiver from providing information under section 106(8)(b) of CEPA. The petition suggests that the situation has now changed, due to inclusion of non-transgenic eggs in the production facility. It asks for details on the containment measures proposed by AquaBounty and whether the company was required to implement the risk measurement and containment measure identified in the 2019 report. The petition also poses a series of questions related to federal government monitoring of the company’s compliance with measures laid out in the 2018 notification document.

Federal Departments Responsible for Reply:  Environment and Climate Change Canada; Fisheries and Oceans Canada, Health Canada.